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Home My WebLink About11-8207MARGARETE CONRAD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW No:_ JAMES FISHER and STEPHANIE FISHER: JURY TRIAL DEMANDED-- PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary: - Please issue a Writ of Summons in the above captioned action. Writ of Summons shall be issued and forwarded to the Cumberland County Sheri ffs Office. $ 9a. vu pad Date: $ Respectfully submitted, a A Rominger & Associates c i71 7 A-d 657 Karl ominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241 -6070 Supreme Court ID # 81924 Attorney for Plaintiff WRIT OF SUMMONS To Above Named Defendants: James and Stephanie Fisher 903 Alison Avenue Mechanicsburg, PA 17055 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Of 0.j. d D. i U- d I Prothonotary Date: Y. eputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy { '-D-OFFICE O 1 hE PROTHON,ITARY 2011 NOY 18 AN 10: 56 Richard W Stewart Solicitor Margarete Conrad vs. James Fisher (et al.) CUMBERLAND COUN e y PENNSYLVANIA Case Number 2011-8207 SHERIFF'S RETURN OF SERVICE 11/02/2011 06:44 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 2, 2011 at 1844 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: James Fisher, by making known unto Stephanie Fis r, Wife-of Defendant at 903 Alison Avenue, Mechancisburg, Cumberland County, Pennsylvania 170 on nt and at the same time handing to her personally the said true and correct copy of the sam . DEPUTY 11/02/2011 06:44 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 2, 2011 at 1844 hours, he served a true copy of the within Writ of Summo s, upon the within named defendant, to wit: Stephanie Fisher, by making known unto herself personal , a 903 Alison Avenue, Mechancisburg, Cumberland County, Pennsylvania 17055 its coy "ts an tat le same time handing to her personally the said true and correct copy of the same. ( rr G SHAW)MARRIS1,51a, DEPUTY SHERIFF COST: $54.44 November 04, 2011 SO ANSWERS, RON r R ANDERSON, SHERIFF .. CowrySuite S'henti, Te;eosoft, Inc. ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW c? P--a 11 N MARGARETE CONRAD, rri n° Plaintiff r1i 2'- N O. 11-8207 Civil C3 Cn =C'? JAMES FISHER and STEPHANIE FISHER,: JURY TRIAL DEMANDED C n Defendants ANSWER WITH NEW MATTER You are hereby notified to plead to the within New Matter within 20 days from the date of service hereto or a default judgment may be entered against you. AND NOW COME DEFENDANTS, BY AND THROUGH THEIR ATTORNEY, GEORGE H. EAGER, AND FILES THE FOLLOWING ANSWER: INTRODUCTION 1-3. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). PARTIES 4. Denied for lack of information. The Plaintiff is not personally known to Answering Defendant and, accordingly, this paragraph can neither be admitted or denied. 5. Admitted. FACTS 6. Paragraphs 1 through 5 of Defendants' Answer are incorporated herein by reference as though fully set forth. 7-8. Admitted. 9. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). 10. Admitted. 11-18. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendants ask that judgment be entered in their favor and against the Plaintiff on all claims set forth in Plaintiffs Complaint. COUNTI NEGLIGENCE OF DEFENDANTS JAMES AND STEPHANIE FISHER 19. Paragraphs 1 through 18 of Defendants' Answer are incorporated herein by reference as though fully set forth. 20-26. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendants ask that judgment be entered in their favor and against the Plaintiff on all claims set forth in Plaintiffs Complaint. NEW MATTER 27. Paragraphs 1 through 26 inclusive above are incorporated herein by reference and made a part hereof. 28. Plaintiffs claims are barred and/or limited pursuant to the applicable Statute of Limitations, the relevant portions of which are incorporated herein by reference. 29. Plaintiffs claims are barred and/or limited by the tort thresholds, applicable by election or law, of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. §1701, et. seq. 30. Plaintiffs claims are barred by the affirmative defenses identified in Pennsylvania Rule of Civil Procedure 1030, including but not limited to (a) waiver; (b) estoppel; (c) statutes of limitation; (d) laches; (e) illegality; (f) release; (g) impossibility of performance; (h) fraud; (i) assumption of the risk; and 0) payment. WHEREFORE, Answering Defendants respectfully demand judgment in their favor and against all other parties together with the costs of this action. DATE: y 1 I Da /av» BY: EAGER, STENGEL, QUINN & SOFILKA George H. Eag , Esquire Attorney for 96fendants I.D. No. 27740 1347 Fruitvilie Pike Lancaster, PA 17601 (717) 290-7971 VERIFICATION I, JAMES FISHER, hereby verify that I am a Defendant in the foregoing action, and that the averments of the foregoing Answers with New Matter to the Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers with New Matter to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false statements made herein. JAMES FISHER Dated: - (o VERIFICATION I, STEPHANIE FISHER, hereby verify that I am a Defendant in the foregoing action, and that the averments of the foregoing Answers with New Matter to the Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers with New Matter to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalt' of 18 Pa.C.S.A. Se 4904, re ing to unsworn falsification to authorities f e tements made her i . . 10% - 0 ? r 7JA ?- ?11 11.4 PHANI FI HER Dates) "?- `? CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer with New Matter upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 EAGER, STENGEL, QUINN & SOFILKA DATE: D 11 D3 j 0/a BY: George H. Ea l, Esqui Attorney for efendan I.D. No. 27 40 1347 Fruitville Pi Lancaster, PA 6 (717) 290-797 F iLEU-OFFiCE THE PROTHONOTARY 2012 JAN -4 AM II: 33 CUMBERLAND COUNTY IN THE COURT OF COMMON PLEAS (RENlt ti MID COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARGARETE CONRAD, Plaintiff NO. 11-8207 Civil V. JAMES FISHER and STEPHANIE FISHER,: JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Interrogatories of Defendant Addressed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 EAGER, STENGEL, QUINN & SOFILKA DATE: U 11 0,-_? ) 12 BY: ?? George r, Esquire Defendants Atto0277,40 I. D. 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARGARETE CONRAD, C - Plaintiff c = -?+ NO. 11-8207 Civil m? f i v. =r n Nr i 8c,' JAMES FISHER and STEPHANIE FISHER: JURY TRIAL DEMANDED Defendants ° xo s" C)-n c , - 25 CERTIFICATE OF SERVICE 5;c= v= " ? I HEREBY CERTIFY that I have this day served a true and correct copy 1 xz of De of hdants' Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiff upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 EAGER, STENGEL, QUINN & SOFILKA DATE: 011 03 hZ BY: George H. Eager squire Attorney for De dants I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 MARGARETE CONRAD, Plaintiff, V. JAMES FISHER and STEPHANIE FISHER, Defendants, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 11-8207 JURY TRIAL REQUESTED PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER AND NOW, comes the Plaintiff Margarete Conrad, by and through her counsel Karl E. .-: Rominger, Esquire and in response to Defendant's New Matter, avers as follows: C__ 27. No answer required. ?'-ri 'te` N r ....E . r I ^ . 4. 28. Denied as a conclusion of law. mac, ..o C5 29 Denied as a conclusion of law. ===+ - -' . 30. Denied as a conclusion of law. WHEREFORE, Plaintiff, Margarete Conrad, seeks damages from Defendants, James Fisher and Stephanie Fisher, in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive of interest and costs. Date: G Respectfully submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff MARGARETE CONRAD, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW NO. 11-8207 JAMES FISHER and STEPHANIE FISHER, : Defendants, JURY TRIAL REQUESTED CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, hereby certify that this date I served a copy of Plaintiff's Answer to Defendant's New Matter, by mailing a copy via USPS First Class, postage pre-paid, addressed as follows: Eager, Stengel, Quinn & Sofilka George H. Eager, Esquire 1347 Fruitville Pike Lancaster, PA 17601 Date: Respectfully submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARGARETE CONRAD, Plaintiff V. JAMES FISHER and STEPHANIE FISHER, Defendants CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ka ?r i' 3 1%) CG As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: r i (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, n NO. 11-8207 Civil z x? use JURY TRIAL DEMANDED :cs s Ca t (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: q // 7 George H. Eage E Attorney for De ar I.D. No. 2774 1347 Fruitvill ike Lancaster, PA 17601 (717) 290-7971 ire PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND Margarete Conrad, Plaintiff Court of Common Pleas Vs. 3ames Fisher AND Stephanie Fisher, Defendants NO. 2009-0489 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Provider: Record Type: Holy Spirit Hospital All available Orthopedic Institute of PA All available Pinnacle Health Neurology Associates All available Magnetic Imaging Center All available Internal Medicine of Mechanisburg All available Dillsburg Family Health Center All available Orthopedic Surgeons of Central Pennsylvania All available TO: Karl E. Rominger, Esquire note: please see enclosed list of all other interested counsel Litigation Solutions, LLC ('LSLLC') on behalf of George H. Eager, Esquire intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Date of Issue: 3/16/2012 CC: George H. Eager, Esquire of Eager, Stengel, Quinn & Sofilka - Court of Common Pleas If you have any questions regarding this matter, please contact: Litigation Solutions, LL.C (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 Litigation Solutions, LLC on behalf of: George H. Eager, Esquire Defense COUNSEL LISTING FOR MARGARETE CONRAD, PLAINTIFF VS. 3AMES FISHER AND STEPHANIE FISHER, DEFENDANTS County of Cumberland Court of Common Pleas Counsel Firm Counsel Type Rominger, Esquire, Karl E. 155 South Hanover Street Carlisle PA 17013 P: 717-241-6070 F: 717-241- 6878 Opposing Counsel CCI?AC1 ujEAE T H LH !'E1\114S? vim, qj-A.- COUNTY ON c114BERL ArgD Margarete Conrad, Plaintiff VS. James Fisher AND Stephanie Fisher, Defendants kikNo NO. 2009-0489 SYMPO E NA TO PRO i JCE.100?JT-AEN T S OR THINGS FOR DISCOVERY PUP?SI A-Iq TO RULE 4009.22 TO. Dillsburg Family Health Center (-Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the cour to produce the following documents or chines: PLEASE SEE ATTACHED RIDER 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed ahove_ You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought- If you fail to produce the documents or things required by this subpoena within twenty (20) days atie_r.ks service, the parry serving this subpoena may seek a court order compelling you to comply R ith it: TES SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: George H. Eager, Esquire ADDRESS.-13427 Lancas , TELEPHONE: - - SUPREMB COURT ATTOP.NEY FOR: eC 1' ° C Date: 13 f S zl of the Cau-E BY TLB COURT: Prothonotary, Civil Division Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Dillsburg Family Health Center 204 Mumper Lane Dillsburg PA 17019 Attention: Records Department Subject: Conrad, Margarete SS#:3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession (1/1/2000 to present) regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. • Films (X-rays, MRIs, CTs), Film lists • Billing records. C01\122i0-NV EAE T- OF rENi? c 'v ± TF CO U TI i OF CITIAMD EP, L A Ni Margarete Conrad, Plaintiff VS. James Fisher AND Stephanie Fisher, Defendants FieNo NO. 2009-0489 L x.J--P-4D'VJJ.ll'=TO PP<0L[JC'E DlIOE...LJLY?N tl S OR Tex n i4 S FOR DISCO-VE f PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: PLEASE SEE ATTACHED RIDER 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought- If you fail to produce the documents or things -required by this subpoena within twenty (20) days afier.iis service, the party serving this subpoena may'seek a court ordei compelling you to comply with ± TES SUBPOENA WAS ISSUED AT TB E REQUEST OF THE FOLL OW1_NG PEP.SONI- NAME: George H. Eager, Esquire ADDRBS-S: Lancaster- - TELEPHONE: - SUPREME COURT b ATTORNEY FOR: e rrs --- Date: 4ac- of ?fllh r Coui BY TBE COURT: Prothonotary, Civil Division Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Holy Spirit Hospital 503 North 12th Street Camp Hill PA 17011 Attention: Records Department Subject: Conrad, Margarete SS#: 3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes)>li>Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. • Films (X-rays, MRIs, CTs), Film lists COh9A--O1Ivy E?, r ,T11 OF rEri?4S ?; i ?_ COUTTTY OF CUlO+TBER i -Ar D Margarete Conrad, Plaintiff kieNo. NO. 2009-0489 VS. James Fisher AND Stephanie Fisher, Defendants SUB-POls'N TO PRODUCE DOCMT N S OR THINGS FOR DISCO77ERY PURSUANT TO RULE 4009.22 `'O: Internal Medicine of Mechanisburg (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the mna to produce the following documents or thin.es: PLEASE SEE ATTACHED RIDER 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the night to seek in advance the reasonable cost of preparing the copies or producing the things sought- If you fail to produce the documents or things required by this subpoena within twenty (20) days after.its service, the party -serving this subpoena may seek a court order compelling you to comply with it: T?JIS SUBPOENA WAS ISSUED AT TlIE REQUEST OF THE FOLL OWNG PEPISON? - NAME: George H. Eager, Esquire ADDRESS: ru Lancasr- , TELEPHONE: - SUPRENM COURT M # ATTORNEY FOR, De Date: ) y /pL S I of the Con t BY THE COURT: Proffionota y, Civfi Division Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Internal Medicine of Mechanisburg 6 Market Plaza Way Mechanicsburg PA 17055 Attention: Records Department Subject: Conrad, Margarete SS#: 3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. • Films (X-rays, MRIs, CTs), Film lists C01?Ol7VW %I. T€1OFPET SYLvai?Ib_ Margarete Conrad, Plaintiff VS. James Fisher AND Stephanie Fisher, Defendants `Le No. NO. 2009-0489 SUR-PGE"1?A TO P P?OLJCE DOCU AEN T S OR TIEENGS FOR DISCO 7ER PUR ?1AN- ? T O RULE 4009.22 Magnetic Imaging Center TrJ: (Name of Person or Entity) ?itbin twenty (20) days after service of this subpoena, you are ordered by the caur to produce the following documents or things: PLEASE SEE ATTACHED RIDER 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 at (Address) You nay deliver or mail Iegible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party mal ; ,g this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sougbt_ If you fail to produce the documents or things required by this subpoena vrithin twrnty (?0) days after.iis service, the parry serving this subpoena may seek a court order cornpelling you to comply with it. T_ S SUBPOENA WAS ISSUED A T THE REQUEST OF TTHE FOLL OWING PEP.SON: NAME: George H. Eager, Esquire ADDRESS: 1 Lancas C , TELEPHONE: - SUPREME COURT M if ATTOP, I EY FOR: D e - B Y THE COURT: Prothonotar} Civil Division Date: Se of e Coto i Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Magnetic Imaging Center 4665 Trindle Road Mechanicsburg PA 17050 Attention: Records Department Subject: Conrad, Margarete SS#: 3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. • Films (X-rays, MRIs, CTs), Film lists CC1 ?-O -jrW A- ,T 101= r t?7?!S ? ?ii COUNT-ii OF CUlABBEPtL .4ND Margarete Conrad, Plaintiff VS. James Fisher AND Stephanie Fisher, Defendants Pie No. NO. 2009-0489 SIMPOEN TO PROIDJCE DGMUEN b S OR TMENGS FOR DISCOVER PURSUANT TO MULES 4009.22 TO: Orthopedic Institute of PA (Name of Person or Entity) Within twenty (270) days after service of this subpoena, you are ordered by the court to produce the following documents or thin.es: PLEASE SEE ATTACHED RIDER at 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (Address) You may deliver or mail legible copies of the documents or produce things requested ley this subpoena, together with the certificate of compliance, to the party making this request at the address listed above- You have the right to seek in advance the reasonable cost of preparing the copies Or producing the things sought_ If you fail to produce the documents or things -required by this subpoena within twenty (20) days afte.r.its service, the parry serving this subpoena may seek a court order cornpelling you to comply 7'ith it: TES SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOW-WG PERSON: NAME: George H. Eager, Esquire ADDRESS: 1 ru vi Lancas er , TELEPHONE: - - SUPREMj COURT M f ATTORNEY FOR, De BY TIM COURT: Daze: ?! p- _ e al of ii'2e Con i Prothonotary, Civil Divisioll Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Orthopedic Institute of PA 3399 Trindle Road Camp Hill PA 17011 Attention: Records Department Subject: Conrad, Margarete SS#: 3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes)Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. • Films (X-rays, MRIs, CTs), Film lists C01Va2O1TW ALT 1 OF P NZNS r v a I Li .- COUI T-Y OF CUl?AEY.L 14J Margarete Conrad, Plaintiff vs. James Fisher AND Stephanie Fisher, Defendants `i1eNo. NO. 2009-0489 SJBp?POENTA TO DISCOVERY CE DOCUMENTS ? p ,[OR (THINGS TO: Orthopedic Surgeons of Central Pennsylvania (Name of Person or Entity) Within twenty (270) days after service of this subpoena, you are ordered by the courtto produce the following documents or lb zs: PLEASE SEE ATTACHED RIDER 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the night to seek in advance the reasonable cost of preparing the copies or producing the things sought If you fail to produce the documents or things -required by this subpoena within twenty (20) days after.its service, the party serving this subpoena may seek a court ordef cornpelling you to comply vdth it TusS SUBPOENA WAS ISSUED AT THE REQUEST OF T BE FOLLOWING PERSON: N-ANE: George H. Eager, Esquire ADDRESS:I. rut vi Lancaster , TELEPHONE: - - SUPREME COURT ID # ATTORNEY FOR: D e e n s B Y TIM COURT: Prothonotary, Civil Di'risior Date: ? ? e21 of he Cowl Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Orthopedic Surgeons of Central Pennsylvania 4310 Londonderry Road 2nd Floor Harrisburg PA 17109 Attention: Records Department Subject: Conrad, Margarete SS#:3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession (1/1/2000 to present) regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. • Films (X-rays, MRIs, CTs), Film lists • Billing records. CO_ O W N ;!i1,T E-{ OF r H 1??t1 V f?1 I d_ COUNTY OF CUI,!-,B ERs r.;J Margarete Conrad, Plaintiff ieNo. NO. 2009-0489 vs. James Fisher AND Stephanie Fisher, Defendants S iRPOE' 14A TO PRODUCE DOCUMENTS OR TU- RiGS FOR DISCOVER PURSUANT TO PALE 4009.22 TO: Pinnacle Health Neurology Associates (Name of Person or Butity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: PLEASE SEE ATTACHED RIDER 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 at (Address) You may debt+er or -pail legible copies of the documents or produce things requested by this subpoena, together with the certificate of comphance, to the party making this request at the address listed above- You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought If you fail to produce the documents or things -required by this subpoena within twenty (20) days after its service, the parry serving this subpoena may seek a court ordei compelling you to'comply oath it: TES SUBPOENA WAS ISSUED AT THE REQUEST OF TIE FOLLOWING PERSON. NAME: George H. Eager, Esquire ADDRESS: I rui vi Lancaste , TELEPHONE: - SUPREME COURT M # ATTORNEY FOR: Def ens F--- Date: a *-Io lh! Court ,!f BY COUR Prothonotary, Civil IJivisiorx D,pu-,y Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Pinnacle Health Neurology Associates 2025 Technology Parkway, Suite 201 Mechanicsburg PA 17050 Attention: Records Department Subject: Conrad, Margarete SS#: 3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. Films (X-rays, MRIs, CTs), Film lists CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 DATE:q / / -7 j_Lx2_ BY: EAGER, STENGEL, QUINN & SOFILKA George H. Eager, Es Attorney for Defen r I.D. No. 27740 1347 Fruitville Pi e Lancaster, PA 1 01 (717) 290-7971 ORIGINA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARGARETE CONRAD, Plaintiff V. JAMES FISHER and STEPHANIE FISHER, Defendants NO. 11-8207 Civil ??`?`" n? JURY TRIAL DEMANDED: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 rm:.ma 7"?a '.e 1 c.? As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which th subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attach to notice of intent to serve the subpoena. DATE: O?lo9 ha quire Georgf'H. /40 Attorney for nt I . D. No. 27 1347 Frui i Lancast PA 17601 (717) 290-7971 1 rl PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND Margarete Conrad, Plaintiff Court of Common Pleas VS. James Fisher and Stephanie Fisher, Defendants No. 11-8207 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS DISCOVERY PURSUANT TO RULE 4009.21 Provider: Record Type: Silver Creek Family Health Center All available TO: Karl E. Rominger, Esquire note: please see enclosed list of all other interested counsel Litigation Solutions, LLC ('LSLLC') on behalf of George H. Eager, Esquire intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Date of Issue: 7/13/2012 CC: George H. Eager, Esquire of Eager, Stengel, Quinn & Sofilka - Court of Common Pleas If you have any questions regarding this matter, please contact: Litigation Solutions, LLC (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 Litigation Solutions, LLC on behalf of: George H. Eager, Esquire Defense COUNSEL LISTING FOR MARGARETE CONRAD, PLAINTIFF VS. TAMES FISHER AND STEPHANIE FISHER, DEFENDANTS County of Cumberland Court of Common Pleas Counsel Firm Counsel Type Rominger, Esquire, Karl 155 South Hanover Street Carlisle PA 17013 P: 717-241-6070 F: Opposing E. 717-241-6878 Counsel COl-v1O!avjLA.L}H Ok PEININS TLVv. 'rgtF_ COUTTI- OF Cuf,AMBEP,L A r4D Margarete Conrad, Plaintiff vs. James Fisher and Stephanie Fisher, Defendants L IC No.?D l 1- R 2 0 7 SU I N TO PRODUCE DOCUI EN T S OR T11MGS f OR DISCO-VERY PURJSI1A_NT TO RULE 4009.22 TO:Silver Creek Family Health Center (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or the zs: PLEASE SEE ATTACHED RIDER at 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought- If you fail to produce the documents or things -required by this subpoena within twenty (20) days after.iis service, the party-serving this subpoena may seek a court order compelling you to'comply with it: - THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLT 0W11',TG PEF?SON: NAM E: (-,fC)rge H aclQr, Esquire ADDRESS: 1 7 F r Litt: v i l l P P i k e T RP z tPr PAS ]2601 TELEPHONE: 71 7- 2 9 0- 7 9 71 -- SUPREME COURT ID # 7 7 Q n _ ATTORNEY FOR:. n t= f P n s t= By THE COURT: 37 wl d :1). &-e ll Prothonotary, Civil- Division! Date. f Seal o the Coen Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Silver Creek Family Health Center 310 Lambs Gap Road Mechanicsburg PA 17050 Attention: Records Department Subject: Conrad, Margarete SS#: 3533 Date of Birth: 01/21/1943 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical the reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff. 9 Films (X-rays, MRIs, CTs), Film lists py CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the forego Certificate Prerequisite to Service of a Subpoena upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 EAGER, STENGEL, QUINN & SOFILKA DATE: D ?l .9//Q BY: Attorney for DefoXai I.D. No. 2774061 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971